Page 1 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

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information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Metals and Controls Corp. SEC-00236 

Petitioner Concerns

Response Paper

National Institute for Occupational 

Safety and Health

June 18, 2019

Pat McCloskey

Mutty Sharfi

Oak Ridge Associated Universities Team

Reviewed By: 

Christine Corwin

James W. Neton, Ph.D. CHP

Timothy D. Taulbee, Ph.D. CHP

Division of Compensation Analysis and Support 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 2 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

INTRODUCTION

The National Institute for Occupational Safety and Health (NIOSH) presented the Evaluation 

Report (ER) for SEC-00236 for the Metals and Controls Corp. (M&C) to the Advisory Board on 

Radiation and Worker Health (Board) on August 24, 2017. At the conclusion of that 

presentation, a petitioner raised a concern about the adequacy of the ER in addressing 

maintenance work. The petitioner stated that he “took great care to define the class of workers 

under evaluation in this petition as precisely and as narrowly as possible to coincide with 

workers for whom there is a high degree of confidence that they received elevated exposures to 

residual radioactive contamination.”

In response to this concern, on September 5, 2017, NIOSH initiated strategies to continue M&C

research and further develop the ER for SEC-00236. These strategies included plans to review 

monitoring records in the Site Research Database (SRDB) and plans to search for former M&C 

workers so that NIOSH could conduct interviews with them.

From October 24 through October 26, 2017, NIOSH, the Oak Ridge Associated Universities 

(ORAU) Team, and Sanford Cohen & Associates (SC&A) personnel interviewed 12 former 

M&C workers and individuals knowledgeable about maintenance work. Interviewers asked 

questions about the frequency and duration of work, including heating, ventilation, and air 

conditioning (HVAC), utility and drain line maintenance, and new equipment installations. 

On December 13, 2018, during a full Board meeting, the M&C Working Group presented an 

update. The petitioners also made a statement and provided a letter with their concerns at the 

meeting.

This response paper addresses concerns recently raised by the petitioner as Oral Testimony to 

Advisory Board on Radiation and Worker Health by Michael J. Elliott, Petitioner for SEC 

No. 00236 on December 13, 2018 (Elliott, 2018).

PETITIONER CONCERNS AND NIOSH RESPONSE

NOTE: The italicized text that follows contains excerpts from the petitioner letter followed by 

responses from NIOSH.

Petitioner Concern 1: Per the instructions of Mr. Ted Katz, Designated Federal Official 

at the Advisory Board on Radiation and Worker Health Meeting #126 (12/13/2018), I am 

providing a transcript of my oral testimony before the Board on behalf of the M&C 

Petitioners for SEC 00236.

This petition pertains to a class of workers at the M&C Facility during the “residual 

period” comprised of Facilities Construction and Maintenance Services Organization 

workers; Equipment R&M workers; and Production Machine Operators/Helpers who 

worked in certain affected areas of the facility. For simplicity, I will follow the same 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 3 of 36

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

convention as the prior speakers, and refer to the entire class of workers covered under 

the petition simply as “M&C Maintenance Workers.” 

First, I would ask us to circle back to the regulation that prescribes procedures for 

designating classes of employees as members of the SEC (42 CFR Part 83). 

Specifically, in Subpart C, Section 83.13 stipulates how NIOSH will evaluate petitions. 

Paragraph (c)(1)(i) states: 

“Radiation doses can be estimated with sufficient accuracy if NIOSH has 

established that it has access to sufficient information to estimate the maximum 

radiation dose, for every type of cancer for which radiation doses are 

reconstructed, that could have been incurred by any member of the class...” 

[Emphasis added]

Paragraph (c)(1)(ii) further states that: 

“...to establish a positive finding under (c)(1)(i) of this section would require, at a 

minimum, that NIOSH have access to reliable information on the identity or set of 

possible identities and maximum quantity of each radionuclide (the radioactive 

source material) to which members of the class were potentially exposed without 

adequate protection.” [Emphasis added]

I contend that NIOSH has failed to satisfy these fundamental regulatory requirements. I 

say this for a number of reasons: 

• Source term characterization is incomplete; 

• Incomplete knowledge of the nature, frequency, and duration of jobs 

performed in intimate contact with the source term; 

• A complete absence of any measurements or monitoring of the workers who 

are covered by this petition; 

• And no comparable population with measurements or monitoring data that 

can be relied on as a surrogate for the class in question. 

NIOSH Response: The definition of sufficient accuracy has been the subject of discussion 

among stakeholders, the Board, and NIOSH since the inception of this project under the Energy 

Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA). As quoted 

above, Subpart C of Section 83.13 states that radiation doses are considered to be estimated with 

sufficient accuracy if NIOSH has access to sufficient information to estimate the maximum 

radiation dose, for every type of cancer for which radiation doses are reconstructed, that could 

have been incurred in plausible circumstances by any member of the class. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 4 of 36

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

NIOSH believes that there is adequate information in the residual contamination period at M&C

to meet the requirement described above. To bound doses to the majority of M&C workers, i.e. 

those that performed production and support tasks, NIOSH used pre-D&D contamination survey 

data from the end of the AWE operational period (1967), in conjunction with data from closer to 

the end of the residual period (1982) (NIOSH 2017). To bound doses to maintenance workers, 

NIOSH used data that was taken before D&D to characterize the subsurface environments, and 

the roof and overhead areas (NIOSH 2018; NIOSH 2019). 

Using our knowledge of the source term of radioactivity that was present and the work activities 

involved with this source term, and the use of surrogate dust-loading data qualified in accordance 

with OCAS-IG-004 (NIOSH 2018), NIOSH believes it has estimated the maximum radiation 

dose that could have been incurred under plausible circumstances. Even under these maximizing 

conditions (e.g., the use of the 95th-percentile and most claimant-favorable solubility types), the 

estimated doses to workers during the residual contamination period are quite small. In general, 

during periods of residual contamination, it was known that NIOSH would typically have access 

to sparse workplace monitoring data and often no worker monitoring data. 

To determine the internal and external exposures to covered workers at Atomic Weapons 

Employer (AWE) facilities during periods of residual contamination, NIOSH developed standard 

approaches that are described in ORAUT-OTIB-0070, Dose Reconstruction during Residual 

Radioactivity Periods at Atomic Weapons Employer Facilities (ORAUT 2012). This document, 

which was specifically written to deal with the reconstruction of doses during periods where 

monitoring data are sparse or nonexistent, incorporates methods that were developed in two other 

NIOSH documents, OCAS-TIB-009, Estimation of Ingestion Intakes (NIOSH 2004), and 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium Metals

(Battelle Team 2011). In the absence of little or no monitoring data, these documents rely on 

surrogate data and models to estimate internal and external exposure. Through its contractor, the 

Board has reviewed each of these documents for scientific validity. Although a number of issues 

and findings were raised during the review process, the Board’s Subcommittee on Procedures 

Review and the Battelle-TBD-6000 Working Group reviewed each finding. Through a series of 

discussions and exchanges of white papers and memoranda, each of the findings and issues was 

resolved. In cases where NIOSH agreed that its original approach needed technical clarification 

or revision, the documents were revised accordingly.

Petitioner Concern 2: As concerns the incomplete source term characterization, the most 

obvious example is the 1996 drain characterization survey in the interiors of Bldg. 10 

and Bldg. 4 where we observed the highest subsurface volumetric activity concentrations 

anywhere onsite. For a number of reasons that I previously described in my 8/29/2018 

written comments, we only analyzed the sediment and soil samples [in the drains] for 

isotopic uranium. Therefore, we can never know for sure what the thorium 

concentrations might have been. (Recall that this was the reason that SEC00149 (NIOSH 

2009) for the operational period employees was granted.)
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 5 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response: NIOSH has addressed the petitioner’s concern about the lack of thorium 

analysis of sediment and soil samples in the Metals and Controls Corp. Thorium and Welding 

Exposure Model white paper (NIOSH 2019).

Petitioner Concern 3: Furthermore, by the time the drain survey was conducted in 1995, 

there had been close to 30 years of disturbances of the drain lines during the residual 

period – they were snaked numerous times, and some of the most plugged sections had 

been removed entirely. Therefore, there is no guarantee that the levels we documented 

[in the drain survey] represent the maximum levels ever present [and to which the M&C 

maintenance workers would have been exposed].

NIOSH Response: NIOSH has addressed the petitioner’s concern regarding the effect of 

30 years of disturbance and removal on the representativeness of sediment analysis in the Metals 

and Controls Corp. Maintenance Exposure Model white paper (NIOSH 2018). In that paper, 

NIOSH stated that the drainage system under Building 10 required frequent maintenance during 

the residual period including the years prior to the characterization. Furthermore, since this 

maintenance could have potentially removed sediments with the highest uranium concentration 

and made the geometric mean of the survey data under-conservative, NIOSH calculated the 95thpercentile concentration and will use it to bound exposures.

Petitioner Concern 4: As has been previously discussed, the gross alpha screening 

analysis methodology that we used for the 1994-1995 comprehensive characterization 

surveys [for the majority of subsurface soils other than the drain survey area] was biased 

low at concentrations above the 30 pCi/gm cleanup standard. Recall that the main 

purpose of the comprehensive characterization surveys was to define the limits of 

excavation, to find clean boundaries. Therefore, we weren’t terribly concerned about the 

low bias of the gross alpha screening method in the areas above the cleanup standard. 

We were more concerned about the high bias in the areas below the cleanup standard. 

[Since we were trying to limit the volume of soil that needed to be excavated, to the extent 

that isotopic analysis of subsurface soil samples was performed to QC the gross alpha 

method results, it would have been preferentially performed in areas that exhibited the 

low concentrations – on the order of 20 to 30 pCi/gm.]

NIOSH Response: The subsurface exposure model developed by NIOSH (NIOSH 2018) used 

data from the following outside areas including the area surrounding Building 10, in the former 

Burial Area, the Metals Recovery Area, the Building 11 Stockade Area, the Building 11 Railroad 

Spur Area, and in the Building 12 West and South Lawn Areas. These areas were characterized 

with 2,391 soil samples collected prior to remediation of each area from 1985 to 1995, and the 

data was presented in the following reports as follows:

• Radiological Survey of the Texas Instruments Site Attleboro, MA. The area was gridded 

and samples were taken at grid intersections. In addition, samples were taken at locations 

of interest (e.g. areas with elevated rad levels) (Sowell 1985, PDF pp. 14-15).

• Radiological Characterization of Texas Instruments, Inc. Attleboro, MA Industrial 

Facility. Grab samples taken every 15-20 feet (CPS 1992a, PDF p.12).
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 6 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

• Radiological Surveys of Open Land Areas Texas Instruments Inc. Attleboro, MA. The

area was gridded and systematically sampled (CPS 1995, PDF p. 10).

• Radiological Survey Results, Appendices 1-4; Creative Pollution Solutions, Inc. The area 

was gridded and systematically sampled (CPS undated, PDF p. 7).

In three of these reports, M&C used an established grid sampling method to determine where to 

take samples, and in the fourth report, M&C used a systematic method to take samples at 

predetermined intervals. NIOSH reviewed the available sampling maps that show where the 

samples were taken and observed that the locations M&C sampled were randomly selected and 

show no apparent bias. 

In addition, NIOSH reviewed the screening method M&C developed to ascertain whether any 

bias was inherent in their analytical process. The M&C gross alpha screening method was 

developed during the pilot study excavation of the former burial area where M&C split samples, 

analyzed half of the samples with their field method, and sent the other half to Lockheed 

Analytical Laboratories for independent verification. M&C determined that their screening 

method results correlated very well with the isotopic uranium analyses by Lockheed Analytical 

Laboratories (CPS 1992a, PDF pp. 12, 37).

NIOSH reviewed the gross alpha screening method used by M&C, including the following 

excerpts:

The technique employed was gross alpha counting of a soil sample in intimate contact 

with a ZnS(Ag) detector. Using this method the ZnS(Ag) disc is disposable. Assuming a 

detector response due to a thick source in contact with ZnS(Ag) is described by:

γ(CPM) = C(Alpha/min/mg) A(cm2

) Rs(mg/cm2)/4.

The sample counting analytical procedure is as follows:

1. The sample is prepared in a sample planchet under original field condition.

2. The range of the alphas in the source material, R1, was calculated using 

Zeigler's theoretical elemental ranges. The elemental ranges were weighted 

by the elemental mass fractions as determined for a standard soil by atomic 

absorption analysis.

3. Since the relative alpha energies were varied, we assumed average energy of

5.5 MeV. The average energy of all alphas emitted by the U-238 chain is 

about 5.4 MeV; the average alpha energy for the Th-232 chain is about 

5.8 MeV.

4. The water content was estimated by drying an aliquot of representative 

samples 1-2 days at 50-75° c. Due to past experience, dry soil was assumed 

to still have 10% water content. Both this 10% and the fraction lost during 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 7 of 36

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

drying were included in the mass fractions for hydrogen and oxygen used in 

(2) above.

5. Uncertainties tabulated with the results are due solely to a propagated

counting error. Due to the assumptions made, especially in (3) above, an 

additional uncertainty could be assumed as a conservative measure (CPS 

1992a, PDF pp. 14-16) 

In practice, M&C used their gross alpha screening method as follows:

The soil sample results were obtained by using the field alpha counting technique 

previously described within the Final Report for the Remediation of the Former 

Radioactive Waste Burial Site, September 1993 (CPS 1992a). Past-established

correlations demonstrated that the gross counts obtained in a 10-minute count 

with the alpha counting technique are equivalent to the total uranium 

concentration in the sample (pCi/g). Alpha screening results of less than 15 

counts/10 minutes have been shown to be equivalent to approximately 2 pCi/g 

total uranium and therefore these results have been treated accordingly for 

purposes of determining grid cell averages. In addition to the results obtained 

from this field technique, 5 % of the samples are being analyzed by gamma 

spectroscopy and 1 % of the samples are being analyzed by alpha spectroscopy 

using an independent laboratory. Past reference samples (from the Former 

Burial Area), are also being selected for independent analysis as a quality 

assurance measure (CPS 1995, PDF p. 10).

NIOSH has reviewed M&C’s sampling practices and gross alpha screening method and has not 

identified a bias that would affect the conservativeness of our exposure model. If the petitioner 

is aware of additional details, please provide specific information to NIOSH as to why the data 

are not only biased but also biased low.

Petitioner Concern 5: In her summary, Ms. Josie Beach referred to the volume of 

residual contamination left over from the AWE operational period that was removed 

during the 1992-1996 decommissioning activities from a site that had ostensibly been 

released for unrestricted use, but that remained present during the residual period 

exposing M&C maintenance workers all the while to unknown and unknowable levels of 

exposure. She correctly referred to hundreds of rail cars of material above the cleanup 

standards that were removed during the decommissioning activities in the 1990s. In fact,

my recollection is that the actual number was on the order of 325 rail cars. The exact 

volume of material removed during the decommissioning project is documented in the 

internal NRC memo to the Commissioners (NRC 1997) dated March 13, 1997, which 

states: “The volume of uranium-contaminated waste generated in the interior 

remediation project was 34,600 ft.3 of soil and concrete rubble. The exterior remediation 

projects generated primarily contaminated soil totaling 532,000 ft.3” That is close to 

600,000 ft.3 that was removed and shipped off by rail to Utah for disposal at Envirocare 

of Utah.
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 8 of 36

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response: The railcars of contaminated material generated after the U.S. Nuclear 

Regulatory Commission (NRC) initially released Building 10 are related to the changing release 

criteria and the subsequent use of more comprehensive investigative methods. Refer to the 

decontamination and decommissioning (D&D) section of the SEC-00236 Evaluation Report

(NIOSH 2017 pp. 17–20) for a chronology of release criteria. The additional contamination

identified using updated methods, including sections of the concrete floor and subsurface 

material, was previously inaccessible, and, as such, did not present a significant exposure hazard. 

It is important to note that although M&C, using updated techniques, was able to find 

contamination throughout the site after the NRC initially released Building 10, NIOSH 

incorporated these additional contamination data (e.g., Burial Area and Building 10 subsurface 

data) into its exposure models. 

Petitioner Concern 6: Concerning the incomplete knowledge of the nature, frequency, 

and duration of jobs performed; the degree of confidence that the NIOSH and SC&A 

technical experts place in the one-month duration estimate for all intrusive activities, 

both subsurface and in overhead areas, seems overly confident, to say the least. When I 

have spoken to these workers, I have never felt that the workers have any solid 

recollection about how frequently or how much time they spent on these jobs. [Only after 

much consternation, and the prodding of Pat McCloskey (of ORAU) after the worker 

interviews concerning the time spent on roof penetration work in the overhead areas, did 

they reluctantly offer some tenuous responses. My co-petitioner, John Elliott, who was a 

Construction and Maintenance working supervisor, responded to ORAU that the roof 

penetration work was a near-daily activity, and he likely spent years of his career doing 

those activities. Another individual, the working supervisor of the instrumentation 

trades, responded to Mr. McCloskey that his people might spend 2-3 months a year 

working on roof projects. He added that maintenance of roof equipment was at least 

weekly and sometimes daily. These estimates were for just the roof penetration work that 

would not have included the additional time doing subsurface work or work in the utility 

pipe-chase service trenches.]

NIOSH Response: Initially NIOSH allowed 1 month of additional exposure for subsurface 

work. However, NIOSH has evaluated additional exposure scenarios for maintenance workers 

(e.g., roof work, overhead area work, HVAC maintenance, and welding) and now provides for 

2 months per year of these enhanced exposures.

Furthermore, according to interviews regarding the evaluated period (1968 to 1997), NIOSH 

understands that workers visited buildings throughout the site and some spent time in the High 

Flux Isotope Reactor (HFIR) area. Interviews also indicated that workers were promoted or 

changed job titles during the evaluated period, which affected their exposure potential (ORAUT 

2017).

When NIOSH considers the experience of M&C workers, it only evaluates exposures to residual 

AWE contamination (e.g., non-HFIR work within Building 10); in addition, NIOSH considers 

the exposure potential for laborers to be different from a supervisor’s exposure potential. It is 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 9 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

also important to understand that for these exposure models, NIOSH assumes that the same 

person does all of the work associated with the highest concentrations of airborne contaminants.

The following interview excerpt illustrates how the maintenance work at M&C was actually

delegated:

Mr. McCloskey: How about the amount of time that you did this kind of work? How 

regularly did you do this? I know that it probably just applied to one phase of your 

career when you had a pipefitter job title. Specifically, we are concerned with 

Building 10.

Worker #1: Right. I would say that there were dozens of times that I worked over there. 

A lot of times when we worked over there, it would take days to finish a job. You had to 

find where the blockage was, saw cut the floor, break up all of the concrete with a 

sledgehammer, excavate it, get down in there and cut the line with a snap cutter, replace 

the line, fill it all in again with soil, and then pour the cement. 

Mr. McCloskey: That’s a big job. Was there a team working with you?

Worker #1: There were other guys. The actual saw-cutting was done by a contractor. 

[REDACTED] would come in and we would tell him where to saw cut the floor, and then 

leave. There were two of us, sometimes maybe three, who would do the rest of the work. 

There weren’t ten guys working on it. This was not a union shop. It was an open shop. I 

couldn’t say to my boss, “I’m not breaking up that concrete. It’s not my job” (ORAUT 

2017).

Petitioner Concern 7: As previously stated, there is a complete absence of any 

measurements or monitoring of the workers who are the subject of this petition. NIOSH 

has relied on measurement and monitoring data for several surrogate populations that 

include the health & safety monitoring of radiation workers at the end of the operational 

period ca. 1968; the health physics monitoring data for the D&D (decommissioning 

project) workers ca. the 1990s; and the Mound Canal project dust loading measurements 

ca. 1997. I would suggest, however, that these populations are not comparable to the 

typical M&C maintenance worker in the class covered by this petition. The surrogate 

classes [proposed by NIOSH] do not adequately characterize the maximum radiation 

dose to any member of the class covered by this petition.

I would ask you to visualize for a moment the typical M&C maintenance worker in this 

class in this time period that may have received the maximum radiation dose. This 

individual would likely fit the following description:

• Plumber, electrician, pipefitter, oiler/lubricator or any of the other Facilities 

and R&M maintenance trades;

• No knowledge of work area exposures to radioactive source materials;
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 10 of 36

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

• No safety/health protocols in place to limit exposures;

• No special PPE or protective clothing required;

• Often came in direct contact with the source material (left over from the 

AWE operational period) in soil, sediments and accumulated dust with no 

knowledge of exposures;

• Wasn’t trained to wear gloves or wash hands after working in these areas –

indeed John Elliott describes handling the tools used to snake out drains with 

his bare hands;

• What decon the individual might have done often involved using shop air 

[compressed air supplied through the facility] to remove gross 

contamination – and that simultaneously created clouds of dust that would 

become respirable;

• Often worked in street clothes, but even if issued a uniform, the individual 

would wear his/her work clothes home and launder them at home as well, 

exposing other family members, and effectively extend his/her exposure to 

contaminants to possibly 24 hours per day, 7 days per week.

The typical M&C maintenance worker in no way resembles the population of workers for 

which NIOSH has relied on measurement and monitoring data as the basis of their dose 

reconstruction modeling.

NIOSH Response: NIOSH interviewed a number of former M&C workers that held titles 

including plumber, electrician, pipefitter, oiler/lubricator, and other Facilities and R&M 

maintenance trades, and those interviews corroborated the petitioner’s concern that there was 

little knowledge of work area exposures to radioactive source materials.

NIOSH analyzed M&C maintenance work including use of personal protection equipment (PPE)

and safety/health protocols, and we modeled associated exposures using plausible circumstances

and without taking credit for any PPE or exposure limiting procedures.

During NIOSH’s research and interviews, it learned that maintenance workers did often come in 

direct contact with the source material (left over from the AWE operational period) in soil, 

sediments and accumulated dust, and that some personal decontamination involved the use of 

compressed air, or that workers remained contaminated when they left the work site. It is 

because of these working conditions and others that NIOSH created additional exposure models 

(e.g. subsurface) to address worker contact with sediments and to allow for longer exposure 

occupancy durations. In addition, NIOSH used maximizing assumptions (e.g. 10-3 and 10-4

resuspension factors) to address work scenarios that involved work with accumulated dust (e.g. 

overhead area and welding).
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 11 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH recognizes there is some uncertainty when trying to bound doses to a class of workers 

that performed multiple and diverse tasks during an extended period. For this reason, NIOSH

applied the use of the 95th percentile radioactivity levels in its models to accommodate any 

uncertainty associated with work process assumptions. It is worth mentioning again here that

NIOSH assumes the same person does all of the work associated with the highest concentrations 

of airborne contaminants, which provides additional conservatism to the exposure models.

Petitioner Concern 8: In a letter to Ms. Josie Beach, dated November 20, 2018, 

Congressman Joseph Kennedy, who represents the 4th Congressional District in 

Massachusetts [which includes the City of Attleboro], acknowledged the uncertainty 

“among members of the work group as to how to evaluate the extent of the radiation 

these workers were exposed to in order to ascertain their eligibility for compensation.” 

But Congressman Kennedy goes further by stating: “It is my hope that the workgroup

takes a broader view and considers the cases of these workers in their final 

determination.”

I feel the Congressman hit the nail on the head with his advice to take a broader view. 

Unfortunately, I fear that NIOSH has failed to take a broader [and more accurate] view 

of the typical M&C maintenance worker. The measurement and monitoring data from 

the 1960s, 1980s and the 1990s for radiation workers and D&D workers, [on which 

NIOSH has relied for their dose reconstruction modeling], are not suitable to estimate 

the bounding dose for the class of M&C maintenance workers.

NIOSH Response: In the SEC-00236 ER, NIOSH created a model to bound doses to the 

majority of M&C workers, i.e. those that performed production and support tasks. After NIOSH 

presented the ER to the Board on August 24, 2017, the petitioner raised a concern about the 

adequacy of the ER in addressing maintenance work. The petitioner stated that he “took great 

care to define the class of workers under evaluation in this petition as precisely and as narrowly

as possible to coincide with workers for whom there is a high degree of confidence that they 

received elevated exposures to residual radioactive contamination” (Elliott 2017, PDF p. 3). In 

response to this concern, NIOSH obtained additional information and developed models in 

subsequent white papers that bound doses to workers that performed more invasive tasks as 

identified by the petitioner.

In addition, the methods for the reconstruction of doses during periods of residual contamination 

have been established, documented, and accepted for use at numerous AWE sites with operations

similar to those at M&C. Refer to the Attachment of this response paper for a detailed 

discussion and chronology of NIOSH and Board interactions that address the reconstruction of 

doses during periods where monitoring data are sparse or nonexistent. For maintenance 

activities that were unique at M&C, NIOSH used monitoring data from measurements obtained 

before D&D along with maximizing assumptions to create bounding exposure models.

Petitioner Concern 9: Following my oral testimony, Mr. William “Rusty” Lorenzen, an 

Operational Health Physicist who worked on the 1990s M&C Decommissioning Project 

and has supported the petitioners since first submitting our SEC petition application in 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 12 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

August 2016, briefly offered some additional comments of his own. Rusty expressed 

grave concerns that NIOSH and SC&A would suggest that the measurement and 

monitoring data collected for D&D workers during the 1990s decommissioning project 

could be used as a surrogate for the types of exposures received by M&C Maintenance 

Workers during the residual period for estimating a bounding dose. Rusty compared this 

to “trying to fit a round peg into a square hole!” He unequivocally dismissed this 

application of the surrogate data as untenable and contrary to any real understanding of 

the two populations. Rusty continued by highlighting the fact that the D&D workers 

operated under strict health physics safety protocols and under the constant surveillance 

of qualified health physics professionals. The M&C maintenance workers, by contrast, 

had none of these benefits (i.e. no health physics monitoring or controls), and as was 

stated numerous times, had absolutely no knowledge of the residual contamination that 

they were exposed to on a regular basis.

NIOSH Response: Although it is arguable whether the D&D work processes (e.g., use of 

Bobcats) produced a lower airborne exposure potential when compared with the work processes 

used to snake clogged drain lines, NIOSH only used the D&D exposure data for its comparative 

value and not for dose reconstruction modeling as alleged by the petitioner. NIOSH used 

monitoring data from measurements obtained before D&D along with maximizing assumptions 

to accommodate any extreme conditions encountered by M&C maintenance personnel to create 

bounding exposure models.

Petitioner Concern 9: Rusty also echoed the remarks of Ms. Josie Beach and a couple of 

the other Board members on the M&C work group who commented that it is virtually 

impossible to identify every conceivable exposure scenario that the M&C maintenance 

workers were exposed to. (One workgroup member likened maintenance workers to 

emergency response personnel who, on any given day, could be asked to do any of a 

number tasks of an unanticipated and unpredictable nature.) Given that reality, it is 

impossible to reconstruct the bounding dose received by any member of this vulnerable 

population in anything that can be considered a scientifically sound and claimant 

favorable manner.

NIOSH Response: NIOSH researched M&C maintenance work and interviewed workers to

model exposures associated with their worst-case tasks. Whenever new exposure scenarios were 

identified, NIOSH evaluated them and created additional exposure models as necessary. NIOSH 

will continue to exercise due diligence in our research to further understand M&C maintenance 

work and ensure that all significant exposure scenarios are addressed.

CONCLUSION

NIOSH continues its research to further understand maintenance work at M&C in an effort to 

create bounding exposure models. In addition, NIOSH will continue to work with all 

stakeholders including the petitioners and the M&C Working Group to expedite these 

evaluations. NIOSH believes all of the exposure models developed to date adequately bound

maintenance exposures experienced by M&C workers during the residual radiation period.
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 13 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

REFERENCES

Battelle Team, 2011, Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, 

Battelle-TBD-6000, Rev. 01, Division of Compensation Analysis and Support, June 17. [SRDB 

Ref ID: 101251] 

CPS (Creative Pollution Solutions, Inc.), undated, Appendix D, Radiological Survey Results, 

Appendices 1-4; assuming the author is Creative Pollution Solutions, Inc. (CPS) based on prior 

work and reports; undated. [SRDB Ref ID: 165968] 

CPS (Creative Pollution Solutions, Inc.), 1992a, Radiological Characterization of Texas 

Instruments, Incorporated-Attleboro Industrial Facility, 1992. [SRDB Ref ID: 164755, pp. 12, 

37] 

CPS (Creative Pollution Solutions, Inc.), 1992b, Texas Instruments Incorporated Remediation 

Plan for the Identified Building 12 Burial Area, 1992. [SRDB Ref ID: 176726] 

CPS (Creative Pollution Solutions, Inc.), 1995, Radiological Surveys of Open Land Areas Texas 

Instruments Incorporated Attleboro, Massachusetts, May. [SRDB Ref ID: 176725, p. 10] 

Elliott, 2017, Petitioners' Written Statement to the Board - Full Board Meeting, August 24. 

[SRDB Ref ID: 176446] 

Elliott, 2018, Oral Testimony to Advisory Board on Radiation and Worker Health By Michael J. 

Elliott, Petitioner for SEC No. 00236, December 13, 2018. [SRDB Ref ID: 176128] 

NIOSH (National Institute for Occupational Safety and Health), 2004, Estimation of Ingestion 

Intakes, Technical Information Bulletin, OCAS-TIB-009, Rev. 0, Office of Compensation 

Analysis and Support, Cincinnati, Ohio, April 13. [SRDB Ref ID: 22397] 

NIOSH (National Institute for Occupational Safety and Health), 2009, SEC Petition Evaluation 

Report for Petition SEC-00149, Metals and Controls Corp., Rev. 0, August 17. [SRDB Ref ID: 

93671] 

NIOSH (National Institute for Occupational Safety and Health), 2017, SEC Petition Evaluation 

Report Petition SEC-00236 Metals and Controls Corp., April 5. [SRDB Ref ID: 176720] 

NIOSH (National Institute for Occupational Safety and Health), 2018, Metals and Controls 

Corp. Maintenance Exposure Model white paper, October 24. [SRDB Ref ID: 174357] 

NIOSH (National Institute for Occupational Safety and Health), 2019, Metals and Controls 

Corp. Thorium and Welding Exposure Model white paper, April 8. [SRDB Ref ID: 175938] 

NRC (U.S. Nuclear Regulatory Commission), 1997, NRC Releases Massachusetts Site for 

Unrestricted Use Following Cleanup of Radioactive Contamination, March 24. [SRDB Ref ID: 

133133] 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 14 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

ORAUT (Oak Ridge Associated Universities Team), 2017, Interview Worker #1; documented 

communication with former Metals and Controls Corporation worker, Oak Ridge, Tennessee,

October 24. [SRDB Ref ID: 169918] 

ORAUT (Oak Ridge Associated Universities Team), 2012, Dose Reconstruction During 

Residual Radioactivity Periods at Atomic Weapons Employer Facilities, ORAUT-OTIB-0070, 

Rev. 01, Oak Ridge, Tennessee, March 5. [SRDB Ref ID: 108851] 

Sowell, 1985, Radiological Survey of the Texas Instruments Site Attleboro, Massachusetts, Final 

Report; L. L. Sowell, Oak Ridge Associated Universities (ORAU); January 1985. [SRDB Ref 

ID: 94371] 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 15 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

ATTACHMENT: ADVISORY BOARD REVIEW OF NIOSH METHODS FOR THE 

RECONSTRUCTION OF DOSES DURING PERIODS OF RESIDUAL 

CONTAMINATION, JAMES W. NETON, PH.D., CHP 

Background 

A number of Atomic Weapons Employer (AWE) sites that produced and/or processed material 

for the Atomic Energy Commission (AEC) became contaminated from the generation and 

settling of airborne radioactive particulate on plant equipment and surfaces. If this material was 

not cleaned up during or after the AEC contract period, any remaining contamination could serve 

as a source of internal and external radiation exposure to workers. As documented in the 

National Institute for Occupational Safety and Health (NIOSH) Report on Residual Radioactive 

and Beryllium Contamination at Atomic Weapons Employer Facilities and Beryllium Vendor 

Facilities, 103 of the 201 AWE facilities evaluated have the potential for significant residual 

contamination outside of the periods in which weapons-related production occurred (NIOSH 

2006).1 In accordance with the requirements of the Energy Employees Occupational Illness 

Compensation Program Act (EEOICPA), NIOSH must reconstruct doses to workers during these 

periods of residual contamination. 

Many of the AWEs that performed work for the AEC were not normally involved in the 

processing of radioactive material. Because of this, these facilities did not have expertise in the 

control and monitoring of radioactive material in the workplace. During the AEC contract 

period, the AEC often provided personnel to perform contamination surveys and air sample 

measurements. During the residual contamination period, however, very little support was 

provided to the AWEs. There were very few surface contamination or air sample measurements

after the AEC contract ended. It was not until the Formerly Utilized Site Redial Action Program 

(FUSRAP) was initiated in 1974 that the levels of residual contamination were systematically 

assessed. 

To determine the internal and external exposures to covered workers at AWE facilities during 

periods of residual contamination, NIOSH uses standard approaches that are described in 

ORAUT-OTIB-0070, Dose Reconstruction during Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities (ORAUT 2012). This document, which was specifically written to 

deal with the reconstruction of doses during periods where monitoring data are sparse or 

nonexistent, incorporates methods that were developed in two other NIOSH documents, OCASTIB-009 (NIOSH 2004) and Battelle-TBD-6000 (Battelle 2011). 

The documents referenced above include methods to calculate the levels of surface 

contamination during residual contamination periods using measured or surrogate levels of air 

concentration, estimate the amount of ingestion, and determine the depletion of surface 

contamination over time. Through their support contractor, Sanford Cohen and Associates 

(SC&A), the Advisory Board on Radiation and Worker Health (the Advisory Board or the 

1 This report can be found on the NIOSH Division of Compensation Analysis and Support website at: 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/rescon/rcontam0811.pdf.
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 16 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Board) has reviewed each of these documents for scientific validity and applicability to dose 

reconstructions under EEOICPA. Using the process established by the Board, all of the findings 

identified in the SC&A review have been evaluated by members of the Advisory Board who 

were appointed to a working group or subcommittee by the Board chair. The conclusions 

reached by each working group or subcommittee were eventually reported to the full Board, 

which accepted their recommendations. Through this review process, all of the findings 

identified in each of the reviews have been officially closed by the Board. That is, through 

discussions and exchange of white papers among the Board, SC&A, and NIOSH, the approaches 

used by NIOSH in ORAUT-OTIB-0070, OCAS-TIB-009, and Battelle-TBD-6000 were 

determined to be scientifically valid and appropriate for the reconstruction of doses under 

EEOICPA. It should be noted that in cases where NIOSH agreed that its original approach 

needed technical clarification or revision, the documents were revised accordingly. The 

discussion below provides the findings that were identified by SC&A in their review and a 

description of the resolution process for each document. Where appropriate, web links to 

documents that were used in the deliberations are provided. 

ORAU-OTIB-0070 

The stated purpose of ORAUT-OTIB-0070 is to provide guidance for estimating doses to 

workers at AWE facilities during periods when NIOSH determined there was “significant 

residual contamination” in its Report on Residual Radioactive and Beryllium Contamination at 

Atomic Weapons Employer Facilities and Beryllium Vendor Facilities (NIOSH 2006) or any 

update to that report. 

Revision 00 of ORAUT-OTIB-0070 (ORAUT 2008) identified the following seven methods that 

may be used to estimate inhalation dose resulting from residual contamination. Selection from 

among the seven methods is based on the availability of data involving air sample measurements 

and surface contamination levels (SC&A 2008): 

1. Use of air sample measurement data taken during and after facility operations allows 

for the determination of the exponential decline in air concentration defined by the 

surface contamination depletion factor coefficient. 

2. Use of operational air-sample measurement data that are adjusted by a source-term 

depletion factor to determine post-operational air concentrations from residual 

contamination. 

3. Use of exponential data fitting that is based on empirical post-operational air-sample 

measurement data and estimated air activities during the facility’s operational period. 

4. Use of surface contamination data taken during and after facility operations. Air 

concentrations from residual contamination are derived for any given year by means 

of an empirically derived surface contamination source-term depletion constant and 

an assumed resuspension factor. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 17 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

5. Use of surface contamination data taken during the operational period and the 

application of a resuspension factor to provide the basis for estimating air 

concentration during the operational period. To estimate air concentration during any 

post operational year, the previously derived operational air concentration is reduced 

by the source-term depletion factor. 

6. Use of surface contamination data taken during the post-operational period and the 

application of a resuspension factor to provide an estimate of the post-operational air 

concentration. For the operational period, a default air concentration is assigned, 

which, in combination with the derived post-operational air concentration, permits an 

exponential fit. 

7. Use of source terms, material quantities, release fractions, and confinement factors to 

calculate potential intake by inhalation. 

SC&A was tasked by the Advisory Board to review Revision 00 of ORAUT-OTIB-0070, and its 

review was provided to the Board’s Procedures Review Subcommittee on August 29, 2008 

(SC&A 2008). In total, SC&A identified 15 findings, 4 of which were classified by SC&A as 

conditional. Conditional findings were defined as those that were linked to three NIOSH 

documents about guidance in ORAUT-OTIB-0070, Battelle-TBD-6000, Battelle-TBD-6001, and 

OCAS-TIB-009. In the opinion of SC&A, the status of these findings depended on future 

revisions to these three documents.2

 

NIOSH evaluated the findings contained in the review by SC&A and provided written responses 

to the Procedures Review Subcommittee and SC&A on June 7, 2010. Subsequent to the NIOSH 

transmittal of their initial responses, the Procedures Review Subcommittee initiated their 

deliberations on these issues at their July 26, 2010, meeting. Their discussion continued during 

parts of the next five meetings. Table 1 provides the dates of these meetings and the page 

numbers of the verbatim transcripts where the ORAU-OTIB-0070 discussions can be found. 

The transcripts for each of these meetings can be found on the NIOSH Division of 

Compensation Analysis and Support (DCAS) website at 

http://www.cdc.gov/niosh/ocas/pubmtgs.html. A matrix of SC&A findings and initial responses 

to those findings by NIOSH is attached to this document as Table 2. 

 

2 Since the time of the SC&A review, Battelle-TBD-6001 has been withdrawn. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 18 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Table 1. Procedure Review Subcommittee 

Discussions of ORAUT-OTIB-0070

Meeting Date Transcript Page 

Numbers

July 26, 2010 282–310 

January 5, 2011 191–289 

July 14, 2011 134–140 

September 19, 2011 74 

April 11, 2012 60–62 

July 31, 2012 45–85 

Over the course of the discussions that were held with the Subcommittee, NIOSH agreed to 

modify key portions of ORAT-OTIB-0070. The most significant modification was the change 

from a default depletion rate of 1% per day to a value of 0.067% per day that was derived using 

empirical data from four separate facilities. On March 5, 2012, the ORAU Team issued 

Revision 01 of ORAUT-OTIB-0070, which NIOSH believes addressed all outstanding issues. 

At the request of the Procedures Review Subcommittee, SC&A reviewed Revision 01 and on 

May 29, 2012, issued an e-mail to the Subcommittee indicating that 13 of the findings should be 

closed. The Subcommittee reviewed and concurred with the SC&A recommendation to close 

those findings at its July 31, 2012, meeting. The remaining two findings (numbers 12 and 15) 

were related to issues with Battelle-TBD-6000 or OCAS-TIB-009 and were to be addressed 

separately during the review of these documents. The issue brought up in finding number 12, the 

assertion that the air concentration values in Battelle-TBD-6000 might not be claimant favorable 

in all situations, was eventually closed under issue number 4 of the Battelle-TBD-6000 review 

(see below). Finding number 15, related to the ingestion model employed by NIOSH, was 

transferred to the Procedures Review Subcommittee and addressed during their review of 

OCAS-TIB-009. 

BATTELLE-TBD-6000 REV. 0 

Battelle-TBD-6000 provides an exposure matrix for workers at AWE facilities that performed 

metalworking operations with uranium metal; the matrix is based on radiological measurements 

that were performed at many AWE facilities when they worked with uranium metal. Over 110 

facilities performed these operations, and this document provides guidance for dose 

reconstruction at any of these facilities. The main body of the document includes general 

discussions of operations and exposure conditions at these facilities. Following the main body of 

the document is a collection of appendices, with each appendix containing information for one 

AWE site that performed metalworking operations. The site-specific information in an appendix 

can be used for dose reconstruction for the site it addresses. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 19 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

During the meeting of the Advisory Board on Radiation and Worker Health held in Richland, 

Washington, on July 17–19, 2007, the Board directed SC&A to perform a review of Revision 0 

of Battelle-TBD-6000 (Battelle 2006).3

 On September 14, 2007, SC&A delivered their review 

of Battelle-TBD-6000, which identified seven findings.4 To evaluate the SC&A report, the 

Board established a Battelle-TBD-6000 Work Group whose original meeting was held on 

November 10, 2008. At this first meeting, SC&A went over the findings and the background 

behind each finding. Because NIOSH had not yet responded to the SC&A findings, further 

discussion was tabled until the next meeting. Prior to the next meeting on March 11, 2009, 

SC&A provided to the Battelle-TBD-6000 Work Group an issues-resolution response matrix, 

which included all seven findings and the written responses from NIOSH to the findings. 

Using the matrix as the basis for discussion, the issues surrounding the findings were discussed 

at subsequent Battelle-TBD-6000 Work Group meetings, which were held on October 14, 2009; 

December 16, 2009; May 12, 2010; and October 12, 2010. At the October 12, 2010, meeting, an 

updated response matrix was issued that summarized the status of the discussions that had been 

held up to that point. Attached to this matrix were eight SC&A and NIOSH white papers that 

were generated during the Battelle-TBD-6000 Work Group deliberations. The response matrix 

and associated attachments can be viewed on the DCAS website at 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsi-tbdim-100710.pdf. As indicated in

the matrix, the Battelle-TBD-6000 Work Group had resolved five of the seven issues, although 

some issues were placed in abeyance until NIOSH made the agreed-to changes in Revision 1 of 

Battelle-TBD-6000 and the Battelle-TBD-6000 Work Group could confirm that the appropriate 

changes were made. The two findings that were not closed (numbers 6 and 7) were related to 

ingestion and resuspension that are dealt with in OCAS-TIB-009 and ORAUT-OTIB-0070, 

respectively. As such, these findings were transferred to the Procedures Review Subcommittee.

BATTELLE-TBD-6000 REV. 1 

During a review of NIOSH documents that relied on the use of Battelle-TBD-6000, Revision 1, 

SC&A discovered some potential issues associated with using that document that were not 

apparent when Battelle-TBD-6000 was originally reviewed. As discussed above, SC&A 

previously reviewed Revision 0 of Battelle-TBD-6000 and, based on the findings, the document 

was revised by NIOSH in 2011 (Battelle 2011). The supplementary comments, as described in 

the SC&A report of May 20, 2013, dealt with four areas: 

1. The suitability of using a terminal settling velocity of 0.00075 m/s and the time required 

to reach an equilibrium surface concentration; 

2. The attenuation rate for surface contamination; 

 

3 Although Revision 0 of Battelle-TBD-6000 included a section to evaluate thorium exposure that was marked as 

reserved, this section was not included in revision 1 and the title was modified to reflect this change. 

4 Although the SC&A report identified these as issues, these are considered synonymous with findings for 

purposes of this discussion. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 20 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

3. A comparison of site-specific air concentrations with generic data used in Battelle-TBD6000; and,

4. Operations not explicitly covered in Battelle-TBD-6000.

Of the areas discussed in the SC&A report, the only one that raised a technical concern was issue 

number 1, the suitability of the settling velocity used in Battelle-TBD-6000 and the time required 

to reach equilibrium. The other three areas of discussion confirmed that the values and/or 

technical approaches used in Battelle-TBD-6000 were appropriate. The full report can be found 

on the NIOSH website at http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-tbd6000-r0.pdf. 

At the Battelle-TBD-6000 Work Group meeting on June 20, 2013, SC&A presented their 

comments on the particulate settling issue. Because NIOSH had not yet prepared a written 

response to the SC&A comments, further discussion was tabled. Subsequent to the meeting, 

NIOSH issued a response paper on the settling issue5 and SC&A issued their responses to that

white paper on October 7, 2013.6

 After considerable discussion of the issue, SC&A agreed in 

principle that the use of a settling velocity of 0.00075 m/s, along with a settling time of 30 days, 

was technically appropriate. However, SC&A indicated they needed a little time to review the 

calculations. On October 14, 2013, SC&A issued a memo that concurred with the NIOSH 

approach to the settling of particulate. In part, the memo stated: 

If the dose reconstructor is required to assume that deposition is continuous for 30 days to 

calculate the amount settled on a surface and to use a default value for the terminal 

settling velocity of 0.00075 m/s, then based on the information presented here, the amount 

deposited will not be understated. 

Based on the latest comments by SC&A, this issue was closed by the Board. 

OCAS-TIB-009 

On April 13, 2004, NIOSH issued OCAS-TIB-009, Estimation of Ingestion Intakes, Technical 

Information Bulletin (NIOSH 2004). In the absence of bioassay monitoring information (e.g., 

urinalyses), there is no direct way to estimate the amount of radioactive material that is ingested 

in the workplace. To account for ingestion when bioassay information is lacking, OCAS-TIB009 relies on a model that correlates the amount of material ingested with levels of airborne 

radioactive particulate that are generated during production and/or processing activities. As part 

of their review of NIOSH procedures that are used in dose reconstruction, the Advisory Board, 

through their contractor SC&A, conducted a review of OCAS-TIB-009. On June 8, 2006, 

SC&A issued a report that contained a review of 32 NIOSH documents that are used in dose 

reconstruction, which included a review of OCAS-OTIB-009 on pages 89 to 93. The concern of 

SC&A with OCAS-TIB-009 was that: “The fundamental scientific approach to reconstructing 

5 Available at: http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-tbd6000-0813.pdf. 6 Available at: http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-tbd6000dst-r0.pdf.
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 21 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

ingestion exposures has flaws that could lead to an underestimate of ingestion doses under 

certain circumstances.” 

Because OCAS-TIB-009 is used to reconstruct doses from ingestion intakes at many covered 

facilities, the SC&A review of this document was transferred as an overarching issue to the 

Procedures Review Subcommittee. Thus, on November 7, 2007, the single finding by SC&A 

was entered into the Board Review System Database as overarching issue number 2. On 

October 23, 2012, NIOSH issued a white paper to the Procedures Review Subcommittee that 

empirically evaluated the approach employed in OCAS-TIB-009 that used surface contamination 

and air concentration data from four AWE facilities.7

 The result of this evaluation supported the 

NIOSH position that there is a linear relationship between air concentration and surface 

contamination. At the Procedures Review Subcommittee meeting on November 1, 2012, there 

was a lengthy discussion between SC&A and NIOSH on the validity of the methodology 

employed in OCAS-TIB-009, which included a discussion of the October 23, 2012, white 

paper.8 

At the end of this meeting, NIOSH agreed to review a U.S. Environmental Protection Agency 

(EPA) document on ingestion intakes that SC&A offered as evidence that ingestion intakes were 

likely to be higher than those estimated using OCAS-TIB-009 (EPA 2003). NIOSH reviewed 

this document and provided a response via e-mail on January 4, 2014, to SC&A and the 

Procedures Review Subcommittee. SC&A reviewed the NIOSH e-mail and entered the 

following response into the Board Review System Database on January 7, 2013 (provided 

below). 

On January 4, 2013, the following email was received from NIOSH (Jim Neton): 

By the way, I did review the World Trade Center exposure paper that was discussed at 

the last subcommittee meeting. My reading of this EPA produced document was that it 

was developed to “identify contaminants of primary health concern .....in support of 

planned residential cleanup efforts in Lower Manhattan.” Thus, the methodology 

described in this document is oriented towards the screening analysis of exposures to 

residents living in the vicinity of the World Trade Center and not oriented towards the 

quantification of exposure to World Trade Center cleanup workers. In light of this, 

DCAS believes that the occupational ingestion parameters contained in the RESRAD 

document (which was used in the recent ingestion white paper) remain the best set of 

data from which to estimate ingestion exposures under EEOICPA. 

SC&A responded: 

 

7 See http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-tib9-102312.pdf. 8 This can be viewed on pages 49 to 98 in the verbatim transcripts of this meeting at: 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/2012/sctr110112.pdf. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 22 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

The RESRAD hand-to-mouth ingestion model may very well be “the best set of data from 

which to estimate ingestion exposures.” SC&A’s problem with it is that it is the only set 

of data from which to estimate ingestion exposures. Sure, in addition to the RESRAD 

document (i.e., NUREG/CR-6755), there is NUREG-5512, Volume 3; ANL/EVS/TM/11-3; 

PNL-4722; ANSI/HPS 1999; and others. The problem is that all of these documents are 

authored by (or refer back to) the same group of individuals out of the Pacific Northwest 

National Laboratory (PNNL). So in effect, all hand-to-mouth ingestion models used by 

the radiological community are based on a single set of data. 

Because it comes from outside of the radiological community and is completely 

independent of the PNNL data, SC&A offered the World Trade Center (WTC) study as a 

benchmark for (rather than as an alternative to) the RESRAD model. The key parameter 

to compare the RESRAD and WTC models is the effective transfer rate (cm2/hr.). These 

rates are dependent on the age of the individual but are independent as to whether the 

individual is a worker or resident. In most non-radiological studies that were identified 

by SC&A, these effective transfer rates were determined for children or toddlers. 

However, the WTC study specifically adjusted the effective transfer rate to be applied to 

adults, another reason SC&A selected it. Using the WTC data, the adult effective 

transfer rates are 11.25 and 2.25 cm2/hr. for hard and soft surfaces, respectively, while 

the RESRAD effective transfer rate is represented by a log-uniform distribution with 

values between 0.28 and 2.9 cm2/hr., with a mean of 1.1 cm2/hr. (DCAS, October 23, 

2012). Comparing DCAS (October 23, 2012) Equation 1 to Equation 2, shows that the 

TIB-009 recommended effective transfer rate is about twice the RESRAD value or 2.2 

cm2

/hr. Considering all of the differences between the WTC study and TIB-009, and all 

the uncertainties involved, this amount of agreement between the hand-to-mouth effective 

transfer rates is considered quite reasonable. 

The difference in the hand-to-mouth ingestion model between workers and residents is 

the exposure durations assumed, not the effective transfer rates. For example, for a 

worker, the duration might be 8 hr./day, 250 days/year, and 20 years. While for a 

resident, the duration might be 12 hr./day, 365 days/year, and 30 years. 

Based on the NIOSH White Paper and the above discussion, SC&A recommends that this 

issue be Closed. 

At the Procedures Review Subcommittee meeting on February 5, 2013, there was a discussion of 

the NIOSH comment on the EPA document and the SC&A response to that comment.9

 After the

Procedures Review Subcommittee completed their discussion, they decided to act on the 

recommendation by SC&A and closed the finding. 

 

9 This discussion can be viewed on pages 58 to 67 and 302 to 313 in the verbatim transcripts of this meeting at 

http://www.cdc.gov/niosh/ocas/pdfs/abrwh/2013/sctr020513.pdf. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 23 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Summary and Conclusion

To determine the internal and external exposures to covered workers at AWE facilities during 

periods of residual contamination, NIOSH has developed standard approaches that are described 

in ORAUT-OTIB-0070, Dose Reconstruction during Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities (ORAU 2012). This document, which was specifically written to 

deal with the reconstruction of doses during periods where monitoring data are sparse or 

nonexistent, incorporates methodology that was developed in two other NIOSH documents, 

OCAS-TIB-009 and Battelle-TBD-6000 (NIOSH 2004, Battelle 2011). In the absence of little 

or no monitoring data, these documents rely on surrogate data and models to estimate internal 

and external exposure. Through its contractor, the Advisory Board has reviewed each of these 

documents for scientific validity. Although a number of issues/findings were raised during the 

review process, the Board’s Procedures Review Subcommittee and the Battelle-TBD-6000 Work 

Group reviewed each finding. Through a series of discussions and exchanges of white papers 

and memoranda, each of the findings/issues was resolved. In cases where NIOSH agreed that 

their original approach needed technical clarification or revision, the documents were revised 

accordingly.
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 24 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

References 

Battelle 2006, Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked 

Uranium and Thorium Metals, Rev. 0; Division of Compensation Analysis and Support 

(DCAS);, effective December 13. [SRDB Ref ID: 30671] 

Battelle 2011, Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked 

Uranium Metals, Rev. 1; Division of Compensation Analysis and Support (DCAS); effective 

June 17. [SRDB Ref ID: 101251] 

EPA (U.S. Environmental Protection Agency) 2003, World Trade Center Indoor Environment 

Assessment: Selecting Contaminants of Potential Concern and Setting Health-Based 

Benchmarks, Prepared by the Contaminants of Potential Concern (COPC) Committee of the 

World Trade Center Indoor Air Task Force Working Group, available at 

https://archive.epa.gov/wtc/web/pdf/contaminants_of_concern_benchmark_study.pdf. 

NIOSH (National Institute for Occupational Safety and Health) 2004, Estimation of Ingestion 

Intakes, Technical Information Bulletin, OCAS-TIB-009, Revision 0, Office of Compensation 

Analysis and Support, Cincinnati, Ohio, April 13. 

NIOSH (National Institute for Occupational Safety and Health) 2006, Report on Residual 

Radioactive and Beryllium Contamination at Atomic Weapons Employer Facilities and 

Beryllium Vendor Facilities, December. [SRDB Ref ID: 29386] 

ORAUT (Oak Ridge Associated Universities Team) 2008, Dose Reconstruction during Residual 

Radioactivity Periods at Atomic Weapons Employer Facilities, Revision 0, ORAU Team Dose 

Reconstruction Project for NIOSH; March 10. 

ORAUT (Oak Ridge Associated Universities Team) 2012, Dose Reconstruction during Residual 

Radioactivity Periods at Atomic Weapons Employer Facilities, Revision 1, ORAU Team Dose 

Reconstruction Project for NIOSH; March 5. [SRDB Ref ID: 108851] 

SC&A 2008, Sanford Cohen and Associates Review of ORAUT-OTIB-0070: Dose 

Reconstruction during Residual Radioactivity Periods at Atomic Weapons Employer Facilities, 

August 29. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 25 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Table 2. SC&A Review Comments on ORAUT-OTIB-0070 and NIOSH’s Initial Responses, July 7, 2010 

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00 

OTIB-0070-01-17 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Inconsistent Use of a Resuspension Factor -- The most obvious flaw 

concerning the default value of the 1% per day source-term depletion as 

derived above is the use of a resuspension factor (K) of 8E-05 per 

meter. This value is nearly 2 orders of magnitude higher than NIOSH’s 

recommended resuspension factor of 1E-06 per meter. 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00 

OTIB-0070-01-17 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

As stated in the OTIB, the removal by ventilation is only one factor, 

which contributes to the reduction in resuspension of contamination 

over time. This is indicated within the text of the OTIB and the 

example shown in the text (citing the 8E-05 value) is presented to 

demonstrate the theoretical resuspension needed if one only considered 

ventilation alone. However, the 1% a day factor is intended to account 

for both the physical reduction in the quantity of radioactive material 

present from all removal mechanisms (ventilation, tracking offsite, and 

dilution over a larger surface area) and reduced susceptibility of the 

material present to contribute to airborne radioactivity levels through 

migration into building surfaces and toward low traffic areas. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00 

OTIB-0070-02-17 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Misinterpretation/Misuse of References -- Section 2.5 of OTIB-0070 

references Sehmel 1980, Till and Meyer 1983, Linsley 1978, and Healy 

1971. A review of these references shows that all but Healy 1971 

pertain to outdoor soil contamination, which involves conditions that 

bear little resemblance to building surfaces, building uses, room heights, 

and ventilation rates. (NOTE: References are defined in the SC&A 

report.) 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 26 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00 

OTIB-0070-02-17 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

The cited text identifies clearly indicates that the referenced studies are 

from outdoor environments: 

The decrease in particulate resuspension with time has been well 

documented in experimental studies in outdoor environments (Sehmel 

1980, Till and Meyer 1983). Measured resuspension factor “half-lives” 

in the range of 35 days to years have been reported (Sehmel 1980). 

Models for this effect have been proposed in the form of a constant 

(steady state component) and a second component with an exponential 

term. For example, Linsley reported an expression (Linsley 1978): 

K(t in days) = [10-6- exp(-0.01t) + 10-9

]m-1 with the 

10-6 factor being replaced by 10-5 for periods of 

“regular disturbance by vehicular or pedestrian 

traffic.” 

Fewer data are available on the variation of resuspension factors 

with time in indoor environments. However, Healy recommends a 

decay constant value of 0.1 d-1

; that represents the effects of source 

depletion with time (Healy 1971). While no experimental studies were 

identified for indoor facilities, an exponential decrease in resuspension 

is expected to occur due to the conservation of mass and the depletion 

of easily suspended contaminants.

The use of the citation from Healy provides an example of the 

specification of a source-term depletion factor in the scientific literature 

and is stated as such; therefore, the cited text is not an example of 

“misinterpretation/misuse of references.” It should be noted that the 

value used by Healy was an order of magnitude higher than that 

recommended by the OTIB (0.1 versus 0.01). 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 27 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-03-18 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Inappropriate Assumption Regarding the Impact of Ventilation on 

Source Term 

Depletion -- Implicit in Equation 5 employed by NIOSH for deriving 

the value of λ (the source term depletion rate) is that airborne 

contaminants are (1) uniformly distributed throughout the interior 

volume of a facility and (2) removed with 100% efficiency. 

Neither of these assumptions is likely to exist. 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-03-18 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

The equation presented in the OTIB is provided as a manner of 

calculating a source term half-life under a given set of conditions (input 

factors). The equation is provided and subsequently used to 

demonstrate the impact of ventilation alone on source depletion. The 

OTIB does not indicate that the source half-life should be calculated 

from these input factors and subsequently applied.
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 28 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00 

OTIB-0070-04-22 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Inconsistencies Exist Between Deriving Operational Air Concentration 

for Uranium 

AWEs (via Battelle TBDs 6000/6001) and Thorium AWEs (via 

Attachment B of OTIB-0070) -- For uranium facilities, the use of 

Battelle-TBDs-6000/6001 identified relatively large air concentrations 

during facility operations that were job specific. In contrast, 

Attachment B of OTIB-0070 identifies but a single geometric mean 

value for each of three thorium sites that more importantly excludes 

process air sampling data, which are likely the most relevant locations 

for assessing air concentrations during, as well as after, facility 

operations. The unexplained inconsistency of excluding process area 

general air samples will lead to inhalation intakes that may be orders of 

magnitude too low. 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00 

OTIB-0070-04-22 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

Air samples were selected to be indicative of general area conditions 

within the facilities to be used as input into an estimate of airborne 

exposure at the start of the residual period. They are not intended to be 

indicative of potential exposure during the operational period. Since the 

general area air samples include contributions from both resuspension 

of residual radioactive material and process releases into the workspace, 

this methodology would be bounding for the start of the residual period, 

at which time process activities have stopped and the only source of 

airborne radioactivity would be resuspension of surface contamination. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 29 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-05-23 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Attachment B Cites Survey Data for Three Separate Thorium Facilities 

but Provides No Further Guidance on How These Data Sets are to be 

Used -- The three data sets identify values that differ significantly, but 

there is no guidance for the dose reconstructor regarding their use. 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-05-23 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

As stated in Section 3.1.5, the thorium air-sample data is intended to be 

used as a bounding estimate of general area air activity for use with the 

exponential attenuation model. 

Guidance on the selection of the dataset is beyond the scope of this 

document since it would need to be based on site-specific data in 

conjunction with OCAS-IG-004. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-06-23 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Use of Horizons’ Summary Survey Data as a Default Value for 

Operational Air Concentration at a Thorium Refining Facility is 

inappropriate and not Claimant Favorable 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 30 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-06-23 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

The document does not specify Horizons summary survey data as the 

default value for operational air concentrations at a thorium refining 

facility. The basis of this finding is unclear. As stated in Appendix B, 

the air sample data sets were selected to be indicative of general area air 

conditions and as such breathing zone and process samples were 

excluded. 

Guidance on the selection of the dataset is beyond the scope of this 

document since it would need to be based on site-specific data in 

conjunction with OCAS-IG-004. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-07-25 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

On the Assumption that the Geometric Mean Value of 4.8 dpm/m3

(cited for Horizons in Attachment B of OTIB- 0070) Reflects Data 

Contained in Exhibit #5, It Is Unclear How This Value Was Derived by 

NIOSH 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-07-25 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

As stated in Appendix B, the air sample data sets were selected to be 

indicative of general area air conditions and as such breathing zone and 

process samples were excluded. A spreadsheet documenting the 

analysis and defining the sample selection will be provided for 

Subcommittee review. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 31 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-08-27 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

The Derivation of Air Concentration Values Cited in Attachment B for 

Nuclear Metals was Not Adequately Explained by NIOSH and Does 

Not Appear to Correspond to Values Reported in the Survey as Given in 

Tables II and IV (AEC 1958). 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-08-27 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

As stated in Appendix B, the air sample data sets were selected to be 

indicative of general area air conditions and as such breathing zone and 

process samples were excluded. A spreadsheet documenting the 

analysis and defining the sample selection will be provided for 

Subcommittee review. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-09-31 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

The Derivation of Air Concentrations Values Cited in Attachment B for 

Lindsay was Not Adequately Explained by NIOSH and Values Does 

Not Appear to Correspond to Those Reported in the Survey 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-09-31 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

As stated in Appendix B, the air sample data sets were selected to be 

indicative of general area air conditions and as such breathing zone and 

process samples were excluded. A spreadsheet documenting the 

analysis and defining the sample selection will be provided for 

Subcommittee review. It should be noted that a data transcription error 

was identified in the original dataset and as such, a revised analysis is

provided. A slight change to the parameters listed in Appendix B is 

warranted (95th percentile changes from 411 to 416 dpm/m3

) and will be 

published in the next revision of the procedure. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 32 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-10-36 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

NIOSH’s Recommended Resuspension Factor of 10-6 per meter is 

Inappropriate. -- Indoor resuspension factors cited in the scientific 

literature that involve substantial industrial activities (as would be 

expected in an AWE facility that may continue to operate after 

operations were performed for the MED or AEC) may experience air 

concentrations corresponding to RF values of 10-4 to 10-3 per meter. 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-10-36 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

The resuspension factors cited represent point measurements and as 

such are not directly comparable to sustained conditions for 2000 hours 

per year under which they are applied by NIOSH. Moreover, a 

probabilistic assessment, conducted using the RESRAD-BUILD model 

and using reasonable estimates of all sensitive parameters demonstrated 

the appropriateness of the 10-6 value. This assessment is documented in 

Attachment A of OTIB-070. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-11-39 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Use of NUREG-1400 as Stated in OTIB-00070 is Both Inappropriate 

and Technically Not Feasible Since the Total Absence of Data 

Precludes a Quantitative Assignment to the Source Term that Reflects 

Residual Contamination. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 33 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-11-39 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

The framework outlined in OTIB 70 is to establish bounding estimates 

of airborne radioactivity and as such, NUREG 1400 provides a 

technically defensible approach. The fact that the NRC and DOE allow 

the use of NUREG 1400 methodology to determine the need for air 

monitoring of radioactivity for compliance with 10 CFR 20 and 10 CFR 

835 are examples of other agencies that have concluded that this 

methodology is considered bounding. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-12-

20/21 

Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Use of Battelle-TBD-6000 for Assigning Operational Air Concentration 

Values May Not be Claimant Favorable 

Under Task Order No. 3, SC&A previously conducted a separate review 

of BattelleTBD-6000 and submitted a working draft report to the Board 

in September 2007. Identified in the draft report was the following 

finding: 

Default airborne dust loadings used in the TBD to derive external 

exposures and inhalation exposures are based on data provided in Harris 

and Kingsley (1959). The TBD would benefit from including a review 

of the time-weighted daily average uranium dust loadings reported in 

the Adley et al. report, Study of Atmospheric Contamination in the 

Metal Melt Building (AEC 1952), and in the site profile for Simonds 

Saw and Steel, ORAUT-TKBS-0032. SC&A’s review of these 

documents revealed that the bounding, default, time-weighted average 

airborne uranium dust concentrations recommended in the TBD might 

not be claimant favorable. 

At this time, the above-cited finding has not completed the resolution 

process and therefore, it is identified herein as a conditional finding. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 34 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-12-

20/21 

Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

Response to SC&A concerns on the application of Battelle-TBD-6000 

methodology is pending resolution of comments specific to that 

document. This item is tracked as Issue 4 in the Battelle-TBD-6000 

issues matrix. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-13-21 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Use of Battelle-TBD-6001 for Determining Inhalation Doses May Not 

be Claimant Favorable 

Under Task Order No. 3, SC&A previously conducted a separate review 

of BattelleTBD-6001 and submitted a working draft report to the Board 

in February 2008. 

Identified in the draft report were the following findings relevant to this 

section: 

It is not possible to judge whether the basic approach to developing 

inhalation doses in TBD-6001 is claimant favorable, based on the 

information presented in that document. However, based on analyses 

presented in this review, it appears that the average inhalation doses 

used in TBD-6001 are not claimant favorable, particularly for the period 

prior to 1948. 

At this time, the above-cited finding has not completed the BattelleTBD-6001 resolution process and therefore it is considered a 

conditional finding herein. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 35 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-13-21 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

Response to SC&A concerns on the application of Battelle-TBD-6001 

methodology is pending resolution of comments specific to that 

document. 

This item is tracked as Finding 1 in the Battelle-TBD-6001 issues 

matrix. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-14-21 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Use of Battelle-TBD-6001 for Determining Inhalation Doses May Not 

be Claimant Favorable 

Under Task Order No. 3, SC&A previously conducted a separate review 

of BattelleTBD-6001 and submitted a working draft report to the Board 

in February 2008. 

Identified in the draft report were the following findings relevant to 

this section: The approach taken by NIOSH to develop year-specific 

correction factors to inhalation doses does not appear to be claimant 

favorable. Doses in the early years may be understated. 

At this time, the above-cited finding has not completed the BattelleTBD-6001 resolution process and therefore it is considered a 

conditional finding herein. 
Response Paper Metals and Controls Corp. 

SEC-00236 Petitioner Concerns

June 18, 2019

Page 36 of 36

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or 

Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. 

This document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that 

is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Date Procedure No. Finding No./ 

Page No.

Procedure 

Title SC&A Findings/NIOSH Initial Response

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-14-21 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

Response to SC&A concerns on the application of Battelle-TBD-6001 

methodology is pending resolution of comments specific to that 

document. 

This item is tracked as Finding 5 in the Battelle-TBD-6001 issues 

matrix. 

08/29/2008 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-15-41 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

SC&A Finding

Many of the Fundamental Assumptions that Form the Technical Basis 

of the OCAS-TIB-009 Ingestion Model are Too Restrictive and May 

Yield Low Values 

Under Task 3, NIOSH’s ingestion model, as described in OCAS-TIB009, was previously reviewed by SC&A in a draft report issued on May 

30, 2006. In that review, SC&A concluded that NIOSH’s model is 

simplistic and is likely to yield intakes that are too low for multiple 

reasons. However, issue TIB-009-01 has not been formally finalized 

and is thus regarded here as a conditional issue. 

07/05/2010 ORAUT-OTIB-0070, 

Rev. 00

OTIB-0070-15-41 Dose Reconstruction 

During Residual 

Radioactivity 

Periods at Atomic 

Weapons Employer 

Facilities 

NIOSH Initial Response

Response to SC&A concerns on the application of OCAS-TIB-009 is 

pending resolution of comments specific to that document.